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Assessment of Criteria Development within the EU Eco-labelling Scheme

4. Comparison with other selected studies

In this chapter the choices taken in other 9 studies will be described shortly in order to reveal similarities and dissimilarities in the chosen LCA approach.

In chapter 3 "Methodological aspects from the Prestudy" many LCA methodological aspects were highligted. Since the studies were prepared in the early 1990´ies the impact assessment methodology within LCA were not very developed. This has not necessarily led to wrong conclusions but the impact assessment framework at that time (medio ’90) is not comparable with todays impact assessment framework. However, the goal and scoping was much more developed within LCA. In chapter 4 "Comparison with other selected studies" the focus naturally will be on the most eco-labelling relevant part of goal and scoping. In chapter 5 "Methodological aspects analysed on the basis of the adopted criteria" the studies are analysed though the criteria and thereby the result of the impact assessment will be emphasised.

On the basis of chapter 3 "Methodological aspects from the Prestudy" and in order to structure the reporting 5 areas are depicted. These are:

	fitness for use,
	functional unit,
	purpose of study,
	product group definition,
	methods for identification of environmental key features.

4.1 Fitness for use

The handling of fitness for use varies from study to study. However, even though it has not been mentioned by name in the three studies of the Prestudy it has not been neglected in any of the studies. On the basis of the Prestudy it seems to be very common to identify allready existing standards which, if they are met, can be a measure for the fitness for use of the products in question.

In the Prestudy it has been looked upon how the fitness for use has been handled. In the text to follow the handling of fitness for use in other investigated studies is presented.

In the study of detergents it is stated that "Detergents are highly competitive products on the market. The dosage recommendation is one of the key criteria and weighted strongly by a weighting factor....."¹⁶. Furthermore a washing performance test is proposed as a measure for how fit the product is for its purpose.

In the study of hairsprays (December 1992, p. VI-15) many considerations concerning fitness for use of hairsprays are presented. The overall goal of these thoughts can be illustrated by the following text "All products qualifying for eco-labels must be fit for use. Unfit eco-labelled products, however environmentally benign, would not be particularly useful and would damage the credibility of the programme". However, this subject is further elaborated and it is stated, that a standard does not exist to be used with respect to the performance of hairsprays at present. The authors to the report therefore propose some kind of test that includes testing for "holding power, duration of hold, drying time, ease of brushout and degree of removal by shampooing" (proposed by French experts). It is further mentioned that the testing should be performed by two experts nominated by the manufacturers of hairsprays in each member state and that no two experts of a member state should come from the same company.

In the study of packaging (June 1992) aspects concerning fitness for use is not considered nor mentioned. The study is still to be finished.

As a result of the study of paints and varnishes a set of criteria of fitness for use is placed. The fitness for use criteria for paints deal with the hiding power of the paint in question. The fulfilment of the criteria is proved by compliance with an ISO standard. The fulfilment of the criteria is proved by compliance with another ISO standard. As in the study of hairsprays many considerations were made in the light of correlation between environment and performance. In this case it is obvious that if the paints do not hide or if the varnishes are not resistant it implies a larger consumption of the product and this could imply a larger burden to the environment.

In the study of paper products the issue of fitness for use is dealt with only in an indirect manner. However done in an indirect way, the subject of fitness for use is touched upon in more parts of the report (Miljøprojekt nr. 179, 1991, p. 15, 29, 40-41), and later in the progress of the development of criteria it was decided that the weight and the quality of the product is correlated positively. This means the higher content of fibres pr. ton product the higher quality. In the first study the fitness for use issue is discussed in connection with matters like "the grammage effect" (p. 15), "the quality aspect" (p. 15) and "paper in comparison with other materials" and "paper in combination with other materials". However, mentioned several times, it is not done in a proper way in the first report but considerations were made later. Later research in the study of paper upon fitness for use showed, that the subject happened to be treated in a correct way, firstly. Further, for the tissue products a sort of correction factor for the absorption of liquid was added in order to take into account the fitness for use. The factor was developed by the industry.

In the study of thermal insulation fitness for use was, however not exhaustive, considered carefully (23, p. 18). The considerations are primarily centered on the thermal performance respectively the thermal properties and the thermal conductivity. As a consequence of this fact a criterion is settled with the purpose of a minimum requirement on the thermal performance. This has to be proved by compliance with an ISO standard. No criteria are settled with respect to the applicability of the different thermal insulation products placed at the marketplace.

In the study of textiles (March 1994, p.55) the aspect of fitness for use is taken care of in the setting of criteria. In the criteria a number ISO standards which the product has to meet are mentioned. These standards deal in general with matters like mechanical and physical properties, colour fastness and for T-shirts a spirality test as well.

In the study of washing machines (August 1992) fitness for use is touched several times. As a conclusion to these discussions it was decided to set a performance criteria. The performance criteria deal with the machines’ ability to wash. The criteria are to meet the requirements of a certain test method in order to prove that the machines are able to wash. The standard is a national standard since an international standard does not exist.

4.1.1 Discussion of fitness for use

The discussion presented below is divided into four main areas. These areas are if the fitness for use is defined at all (and how) in the studies: if the proposed demand of fitness for use is relevant, if there is a correllation between the defined fitness for use and the environmental performance of the products and if the fitness for use demand is based on the results obtained from the LCA study.

In all the investigated studies but packaging fitness for use is considered. This does not only mean, that the subject has been considered but also that demands are proposed in all studies except packaging. In many of the studies the criteria concerning fitness for use is based on some sort of (international) standard. This is the case for light bulbs, refrigerators and freezers, detergents, paints and varnishes, thermal insulation, textiles and washing machines. The proposed standards are international recognised in all studies but the study of washing machines. The standard proposed for washing machines is national. In the study of light bulbs criteria that are not based on standardisation are proposed as well. For soil improvers, hairsprays and paper no standards are mentioned, but the matter is handled in different ways. For soil improvers a number of fitness for use demands have to be met, for hairsprays an expert panel is proposed and in the case of paper the problem is solved by the use of the functional unit and if relevant a correction factor.

The considerations concerning fitness for use is on the one hand manyfold while on the other hand not always brought into effect in a useful way. In many cases this is because it is a difficult task. In the case of light bulbs it would have been useful to propose a criterion concerning the provision of light for the purpose of use throughout a minimum time period. In the case of soil improvers it would have been useful to propose a fitness for use criterion concerning the content of bulky material. For thermal insulation the life time of the product would have been relevant. The life time of the product was considered thoroughly but an international recognised standard did not exist.

In more of the studies it is identified that there is a positive correlation between the reduced environmental burdens and the (quality of) fitness for use performance of the products. This is the case of light bulbs, refrigerators and freezers, detergents, packaging, paints and varnishes, thermal insulation and washing machines.

The correlation between the environmental aspects and fitness for use is only identified through the use of LCA in very few studies. Even though this aspect is mentioned in more reports this is then caused by the imagination of the authors. In fact the correlation is only identified through figures in the study of detergents, hairsprays (partly) and paints and varnishes. In the study of soil improvers the exclusion of the waste aspect in connection to the use phase is questionable since any potential residues (heavy metals, resistant compounds etc.) of the soil improvers can be considered as being a waste product, e.g. contributing to soil pollution one of the impacts not dealt with in the LCA. In that case, the residues should be regarded as any other in- and output in connection to the soil improvers life cycle and not only dealt with as a fitness for use aspect.

The limited use of LCA means that even though the results are reliable, they are not actually proved in the studies. This is really a pitty since one of the very basic ideas of the LCA is to challenge dogmas and thereby verify these or the reject them. Thus, the reason for focusing on fitness for use is the credibility of the label, e.g. a bad functioning eco-labelled product could lead to credibility problems to the label in general.

4.2 The functional unit

The functional unit is the key measure of environmental performance which the system that is investigated delivers. It has to be clearly defined, measurable and relevant to input and output data. Examples of a functional unit is "the amount of detergents necessary for a standard household wash" or "the packaging used to deliver a given volume of beverage" (16).

In this section it is described if a functional unit is defined in the studies and whether the defined (or non-defined) functional unit is used in the studies. In the situations when a functional unit is not defined, the way the comparison among different products has been handled is described. Limitations of the defined functional unit, inclusion of other functions in the definition of the functional unit and the workability of the functional unit is discussed.

The picture obtained from the Prestudy of the definition and use of the functional unit is very inhomogenous. The results from the other investigated studies will be presented in the following text. Like it was shown in the Prestudy it is varying to which extent attention is paid to the definition of the functional unit and like the generel trend from the Prestudy, many difficulties and inaccuracies were introduced when the functional unit was defined.

In the study of detergents no functional unit was defined. (11). In the criteria document of March 1993 "the criteria are related to Gramm (g) per Wash respectively Gramm per kg dry textile and the critical dilution volume in liters per wash (l/wash). Provisionally g/wash is used but it has to be converted to g/kg textile as the heavy duty detergents are related to: dosage per 4,5 kg load (dry textiles) and the low duty detergents to dosage per 2,5 kg load in the washing machine".

Thus, some sort of unit for comparison was established by the g, g/wash, g/l and g/kg units. The matter of the ability to wash and clean clothes - the washing performance - was discussed but a functional unit was not defined.

In the studies the data connected to the inventory and/or the impact assessment are not related to any firm unit. Some of the data are related to the g/wash as mentioned above. Other data are connected to predicted environmental concentrations, PED while others use other units.

As mentioned above the criteria are related to units for comparison but not what is normally meant to be a functional unit.

In the study of hairsprays (7) a functional unit was defined. This was determined to be the volume of liquid formulation. The quantity used was determined to be an equivalent pump litre (p. V-3).

The functional unit was not used in the inventory stage of the LCA. It was argued that this is not necessary in order to determine which stages of the life cycle that contributes the most to the environment (IV-8).

The criteria are set up with the equivalent pump litre as a basis for comparison.

In the study of packaging (21) a functional unit is not defined. The subject is not discussed but in the section of the report dealing with "Packaging as a group of products" some considerations concerning "Determining a reference base for packaging" are made. However, the reference base is not used in the study. Criteria are not established in the study.

In the study of paints and varnishes "the functional unit used for analysing the inventories of the paint is: the amount of paint necessary to cover 20 m² with an opacity of 98%" (8, p. 9). Further, in the section dealing with "The General Methodology for Life Cycle Inventory", it is stated that the flows listed in the Life Cycle Inventories are not calculated for physical quantities of the products, but on the basis of the performance of an equivalent service.

The criteria of paints and varnishes are split up into several groups. These groups are gloss and non-gloss paints, and water- respectively VOC-based paints and varnishes. In the report (8) it is argued (at page 12) that the classification is based on the function of the paints and stems from the discussions of the ad hoc working group members about the volatile organic componds content of the paints which have shown that the VOC content and various characteristics of the paints (washability, gloss, hiding power, corrosion resistance ...) are closely related through the Pigment Volumic Concentration (PVC). This split up on the basis of funtion makes it look like either another definition of product group should have been chosen or the criteria should have been presented in a more general manner. Seen from a Danish perspective another understanding could to a much wider extend have lead to criteria promoting non-VOC products.

Some of the criteria are related to the functional unit. Some of the criteria are not related to the defined functional unit directly. These are set up with a general purpose like general requirements with respect to information to the end user.

In the first published report on paper products (12, 13, 14) a functional unit was not discussed and it was not defined. Some attention was paid to the so-called grammage effect but this matter was not further developed. The data used for the inventory were based on a per kilogramme basis.

The set of criteria that was developed first also related to a kilogramme basis. Except for the criteria that are related to more general issues like sustainable forestry.

At later stages of the work it was concluded that the per kilogramme basis was the right choice, and it was concluded that the grammage effect was the best factor to use. For the case of kitchen rolls that was later corrected by a factor of absorption.

When a per kilogramme basis is chosen as a functional unit for these types of products, this does to some extent include a measure of quality as well.

For textiles the definition of a functional unit was paid much attention, and it was decided to use kilogramme of fabric as a basis. The data in the inventory are not related to a specified functional unit.

The criteria are related to the defined functional unit except in the situations where this is too rare, e.g. the fitness for use criteria. Some of the criteria deal with general environmental aspects and these are not related to the functional unit.

In the study of thermal insulation the functional unit was defined very early in the process of developing criteria. The functional unit includes some quality aspects, e.g. the products thermal insulation property, while the durability of the product and e.g. technical building characteristics as carrying capacity are not included.

The data of the inventory are presented both with respect to per kilogramme basis and with respect to per functional unit basis.

The criteria are in general related to the defined functional unit. Some of the criteria deal with general environmental aspects and these are not related to the functional unit.

In the study of washing machines no functional unit was defined. However, the data in the inventory use a per kilogramme basis for comparison and the criteria, except the general related ones, are set up with a per kilogramme basis.

4.2.1 Summing up the results of the going through of all studies

As already indicated in the introduction to this section it is varying very much to which extent a functional unit is defined or for the matter of that if and how the functional unit is used in the study and in the criteria. In many of the studies it is very hard to determine whether one could say yes or no to these questions. However, in Table 4.1 it is indicated with the sign of plus or minus what is the closest answer to these questions. The table can not stand alone but it is meant to be a help in order to get an overview.

Table 4.1¹⁷
In the table it is indicated - by the use of "+" and "-" - to which extent the functional unit is defined and used in the studies.

More of the functional units include to a certain degree other aspects than the primary function. This can be aspects like life time and quality. Life time of the products is included in the functional unit of light bulbs. In the studies of hairspray, paints and varnishes, textiles and washing machines life time is a part of the study, e.g. durability is discussed. In these studies it has been chosen not to include the matter in the functional unit but the subject has been taken care of when relevant in other ways, e.g. in the criteria or in the fitness for use criteria.

The quality of the products is a very general issue in the investigated EU eco-labelling studies. In most cases it is argued that for the credibility of the scheme it is very important that the coming-to-be-eco-labelled products are of high quality.

For some of the products the quality aspect is partly included in the functional unit. This seems to be the case in the study of hairspray, paints and varnishes and paper products.

Quality

The quality aspect is further discussed in the section dealing with the setting of criteria.

The definition of product groups and the definition of functional units are areas that arise too many potential conflicts. This is often because the functional unit can cover a wide area of product groups which in fact are more (different) product groups. This conflicting situation arises in several of the studies where a functional unit is defined. That is the case for light bulbs and partly the case for cooling appliances, hairspray, paints and varnishes, paper, textile and thermal insulation. This situation can be difficult to handle and one has to take care in order to make exact references and definitions.

4.3 Purpose of the study

In this section it is described how different eco-labelling studies have handled the item "purpose of the study".

Several of the investigated studies refer to the eco-labelling regulation in the description of the purpose of the study. It is, however, not the same articles of the regulation they are referring to.

In the study of paper (12, 13, 14) there is a reference to article 1, section 3 defining environmental impact in the following way: "The reduction of the environmental impact will be achieved through minimisation of:

	use of natural resources and energy resources,
	emissions into air, water and to soil,
	generation of waste and noise

and through the maximisation of product life, and where applicable, through the use of clean technologies to ensure a high level of environmental protection".

In the study of thermal insulation reference is made to article 1 in it's full length. The text in the report of thermal insulation states that the "criteria should be able to meet the demand of the Council Regulation, which in this context is defined as promotion of design, production, marketing and use of products which have a reduced environmental impact during their entire life cycle and at the same time to provide consumers with better information on the environmental impacts of products(23, p. 23). The same reference to the Regulation is made in the study of textiles (15, p. 4) and detergents (11, p.2).

As mentioned above the paper study is divided into two parts. In this context the scope and system boundaries will be considered on the basis of the full study. The first part is a qualitative description rather than a quantitative collection of data upon which the most important phases with respect to the environment have been pointed out. This report was made by an expert (from the Swedish Pulp and Paper Research Institute) and discussed among experts and to some extent member states within the EEC - a sort of open peer review was made then.

In the study of paints and varnishes articles 4 and 5 of the Council Regulation are emphasised, and it is stated that "three kinds of criteria are distinguished:

	the ecological criteria, which are determined according to a global approach (from cradle to grave),
	the criteria which refer to general principles (toxicity...),
	the fitness for use criteria, to ensure that the product should have at least a minimum level of quality."

Some of the studies do not refer to the Council Regulation but state a purpose of the study.